First of all, I believe passenger rights should be incorporated in the primary legislation, not in regulations. Regulations they can suspend, and do suspend, on a whim. Second, even before the APPR, passengers had a right to a refund when the airline cancelled a flight for any reason. That hasn't changed. It could be incorporated and should be incorporated in the APPR simply to have a single document that lists all those rights.
The other major issue of concern relates to who has the burden of proof, when a flight is cancelled or delayed, of whether or not it was in the airline's control. There's this whole idea that if a flight was cancelled or delayed for maintenance reasons, then the airline is off the hook. That is inconsistent with international standards. Canada should generally adopt the European Union's gold standard. In the European Union, there are no such issues with refunds. The European Union made it clear to all states that they have to enforce the right of passengers to a refund, which is clearly enshrined in the European regulations.